ATTACHMENT I: EXISTING ENVIRONMENT & IMPACT OF THE ACTIVITY

Transcription

1 Industrial Emissions, Application Form, V.3.0, January 2015 ATTACHMENT I: EXISTING ENVIRONMENT & IMPACT OF THE ACTIVITY Attachment I.1 Assessment of Atmospheric Emissions This attachment contains the following: I1.1 Air Dispersion Modelling Report 287-X0244 March 2015

2 Air Dispersion Modelling Report In support of an application for the review of Industrial Emissions Licence No P Prepared for: Diageo Ireland Ref: 287-X0245 March 2015 Byrne Ó Cléirigh, 30a Westland Square, Pearse Street, Dublin 2, Ireland. Telephone: Facsimile: Admin@boc.ie. Web: Directors: LM Ó Cléirigh BE MIE CEng FIEI FIMechE; TV Cleary BE CEng FIEI FIChemE; LP Ó Cléirigh BE MEngSc MBA CEng MIEI; ST Malone BE MIE CEng MIEI; JB FitzPatrick FCA. Registered in Dublin, Ireland No

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4 Air Dispersion Modelling Study in Support of Application for Review of IE Licence i DISCLAIMER This report has been prepared by Byrne Ó Cléirigh Limited with all reasonable skill, care and diligence within the terms of the Contract with the Client, incorporating our Terms and Conditions and taking account of the resources devoted to it by agreement with the Client. We disclaim any responsibility to the Client and others in respect of any matters outside the scope of the above. This report is confidential to the Client and we accept no responsibility of whatsoever nature to third parties to whom this report, or any part thereof, is made known. Any such party relies upon the report at their own risk. 287-X0245 March 2015

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6 Air Dispersion Modelling Study in Support of Application for Review of IE Licence ii Contents EXECUTIVE SUMMARY INTRODUCTION SITE DESCRIPTION Production Activities Emission Sources Site Environs DISPERSION MODELLING SCENARIOS Overview Nitrogen Oxides Total Organics Particulate Matter DISPERSION MODEL Modelling Programmes Input Data Background Concentrations Modelling Outputs ASSESSMENT CRITERIA Nitrogen Oxides Total Organics Particulate Matter ASSESSMENT OF RESULTS Introduction Nitrogen Oxides Total Organics Particulate Matter Cumulative Impact Assessment Protection of Vegetation SENSITIVITY STUDY CONCLUSIONS Overview Nitrogen Oxides Total Organics Particulate Matter Overall Site Impact APPENDIX A: SITE LAYOUT APPENDIX B: WIND ROSES FOR DUBLIN AIRPORT APPENDIX C: BACKGROUND MONITORING DATA APPENDIX D: CONTOUR PLOTS FROM DISPERSION MODEL APPENDIX E: ASSESSMENT OF GROUND LEVEL CONCENTRATIONS AGAINST AIR QUALITY STANDARDS 287-X0245 March 2015

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8 % of Air Quality Standard (AQS) Byrne Ó Cléirigh Consulting Air Dispersion Modelling Study in Support of Application for Review of IE Licence 1 EXECUTIVE SUMMARY This report by Byrne Ó Cléirigh covers an air dispersion modelling study carried out for Diageo Ireland, St. James s Gate, Dublin 8. The air dispersion modelling study was conducted in support of an application to the Environmental Protection Agency for the review of Diageo s Industrial Emissions Licence in light of the installation of a fourth roasting plant. This is the third such air dispersion modelling study carried out for the site, The study was conducted to predict ground-level concentrations of nitrogen oxides (as NO 2 ), total organics (as C) and particulate matter (as TPM, PM 10 and PM 2.5 ). These parameters are discharged to atmosphere from a number of sources at the site. This dispersion modelling study is the third such study that has been carried out in recent years. The previous two studies were also carried out to support applications for licence reviews, the first to cater for the installation of the third roaster, and the second to cater for the construction of Brewhouse 4 and associated works. For the purpose of the current study, the discharges from both the current boiler and main emission points, and the new emission points associated with the fourth roaster, have been modelled. The objective of the study was to assess the predicted concentrations of oxides of nitrogen, total organic carbon, and particulate matter in the context of ambient air quality standards as set out in the Air Quality Standards Regulations, and other guidelines. The results were also assessed in the context of data from ambient air monitoring surveys conducted by the EPA at two stations in the vicinity of the site. The dispersion modelling was conducted using BREEZE AERMOD software together with related BREEZE software packages for processing meteorological data and building downwash data. The model incorporated digital terrain data and was run for three years of weather data for Dublin Airport weather station (2008 to 2010). The modelling was conducted in accordance with the EPA s Air Dispersion Modelling from Industrial Installations Guidance Note (AG4). The results of this analysis are illustrated in Figure 1 to Figure 4. Figure 1: Predicted Environmental Contribution of NO 2 (Annual Average) 100% Predicted Environmental Contribution of NO 2 Emissions in the context of the Annual Average AQS & Background Concentration 80% 18.7% 5.5% 7.0% 60% 40% 20% AQS 72.0% 72.0% 72.0% 0% AQS Max. Allowable PEC Existing PEC Future PEC Background Concentration Process Contribution 287-X0245 March 2015

9 % of Air Quality Standard (AQS) % of Air Quality Standard (AQS) Byrne Ó Cléirigh Consulting Air Dispersion Modelling Study in Support of Application for Review of IE Licence 2 Figure 2: Predicted Environmental Contribution of TOC (1-Hour) 100% Predicted Environmental Contribution of TOC Emissions in the context of the 99th percentile 1-hour Air Quality Guideline 80% 60% 40% 20% 0% AQS 66.7% 21.6% 28.6% 0.0% 0.0% 0.0% AQS Max. Allowable PEC Existing PEC Future PEC Background Concentration Process Contribution Figure 3: Predicted Environmental Contribution of PM 10 (Annual Average) 100% Predicted Environmental Contribution of PM 10 Emissions in the context of the Annual Average AQS & Background Concentration 80% 60% 40% 20% 0% AQS AQS 44.2% 4.9% 5.0% 4.9% 5.0% 33.8% 33.8% 33.8% 33.8% 33.8% Max. Allowable PEC Existing PEC Existing + Roaster 4 PEC Existing + Rice Discharge PEC Future PEC Background Concentration Process Contribution 287-X0245 March 2015

10 % of Air Quality Standard (AQS) Byrne Ó Cléirigh Consulting Air Dispersion Modelling Study in Support of Application for Review of IE Licence 3 Figure 4: Predicted Environmental Contribution of PM 2.5 (Annual Average) 100% Predicted Environmental Contribution of PM 2.5 Emissions in the context of the Annual Average AQS & Background Concentration 80% 60% 40% AQS 37.6% 0.2% 0.2% 0.2% 0.2% 20% 43.6% 43.6% 43.6% 43.6% 43.6% 0% AQS Max. Allowable PEC Existing PEC Existing + Roaster 4 PEC Existing + Rice Discharge PEC Future PEC Background Concentration Process Contribution The main conclusions from the air dispersion modelling study are: The modelling has been conducted in accordance with the EPA s Air Dispersion Modelling from Industrial Installations Guidance Note (AG4) and the emissions from the site have been modelled on a conservative basis. The results show that the offsite ground level concentrations of nitrogen dioxide are, and will continue to be, less than the air quality standard. The offsite ground level concentrations of Total Organics are, and will continue to be, significantly below the air quality guideline value. The concentrations of the various organic compounds that make up the TOC emission are, and will continue to be, less than their respective environmental assessment levels. The offsite ground level concentrations of particulate matter (TPM, PM 10 and PM 2.5 ) are, and will continue to be, significantly less than the respective air quality standards X0245 March 2015

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12 Air Dispersion Modelling Study in Support of Application for Review of IE Licence 4 1 INTRODUCTION This report by Byrne Ó Cléirigh describes an air dispersion modelling assessment for Diageo Ireland, St. James s, Dublin, in support of an application to the Environmental Protection Agency for a review its Industrial Emissions licence, Register No. P The application for the review relates to the installation of a fourth roasting plant and associated afterburner, which will introduce two new main emission points to atmosphere, one of which will discharge nitrogen oxides and total organic carbon, and one of which will discharge total particulate matter. The air dispersion modelling study has also been carried out to assess the ground level impact of particulate matter emissions arising from changes to the arrangement of a number of emission points to atmosphere at the Raw Materials Handling (RMH) building adjacent to Brewhouse 4. The modelling predicted the ground level concentrations of nitrogen oxides (as NO 2 ), total organics (as C) and total particulate matter arising from the discharges at: the existing CHP plant on the Lower Level; the three existing roasting plant afterburners and cooling stacks on the Upper Level; the existing grain intake area on the Upper Level; the existing grain intake and handling systems at the RMH building adjacent to Brewhouse 4 on the Lower Level, and the new roasting plant afterburner and cooling stack on the Upper Level. In assessing the emissions of total particulate matter from the site, the contribution of particulate matter as PM 10 and PM 2.5 has also been assessed. The modelling was conducted in accordance with the EPA s Air Dispersion Modelling from Industrial Installations Guidance Note (AG4) and the predicted ground level concentrations were assessed in the context of ambient quality standards and guidance values, taking into consideration background concentrations. 2 SITE DESCRIPTION 2.1 Production Activities Diageo Ireland produces stout, ales, lagers and alcoholic products at the site for the Irish, UK, mainland Europe and North American markets. In addition, a Guinness concentrate is produced for export to the worldwide market. The production process for this concentrate is similar to that for the stout, ales and lagers, but includes an evaporation / concentration unit to produce the concentrate. The main production activities that currently take place at the site are: Raw materials intake and storage. Roasting of barley. Brewhouse processes (including milling of malt and roast barley, mashing and boiling of the wort). Fermentation Plant processes (including addition of yeast, centrifugation, maturation and blending). Filtration. 287-X0245 March 2015

13 Air Dispersion Modelling Study in Support of Application for Review of IE Licence 5 Pasteurisation, racking and packaging in the Keg Plant for distribution to the domestic and export markets. Transfer to bulk tankers for dispatch to packaging sites within Guinness Supply. Production of concentrate in the BBA Plant. In addition to the production activities at the site, there are a wide range of services and ancillary activities that take place, including: Bulk and packaged chemical (including acid and caustic) intake and storage; Carbon dioxide collection and recovery; Catering; Cleaning-in-place (CIP); Compressed air; Distribution fleet fuelling; Effluent neutralisation; Electricity and heat generation and distribution (CHP Plant); Forklift truck maintenance and repair; Keg cleaning; Laboratory activities (including a radiation source); LPG storage and distribution; Medical Department; Nitrogen generation & distribution; Office and building cleaning services; Refrigeration (including ammonia & glycol systems); Storage areas; Surface water and effluent drainage; Water supply, treatment, and distribution; and Workshop activities (including welding, cutting and fabrication). 2.2 Emission Sources Existing Emissions There are five boiler emission points to atmosphere, all of which are associated with the Combined Heat and Power (CHP) plant on the Lower Level. There are also sixteen main emission points to atmosphere at the site, as follows: three associated with the afterburners on the three existing roasting plants, three associated with the grain intake area at the Robert Street Building on the Upper Level, three associated with the cooling stacks on the existing roasting plants, seven associated with the intake and handling of grain at the RMH Building adjacent to Brewhouse 4 on the Lower Level. 287-X0245 March 2015

14 Air Dispersion Modelling Study in Support of Application for Review of IE Licence 6 These emission points to atmosphere (boiler and main) are summarised in Table 1. Table 1: Summary of Existing Licensed Emission Points to Atmosphere Source # Emission Points Modelled Emissions CHP Plant 5 Nitrogen Oxides Afterburners on Roasting Plants 3 Nitrogen Oxides Total Organics (as C) Cooling Stacks on Roasters 3 Total Particulate Matter Grain Intake (Upper Level) 3 Total Particulate Matter Grain Intake & Handling (Lower Level) 7 Total Particulate Matter New Emissions As noted in Section 1, the introduction of the fourth roaster and afterburner will introduce two new main emission points: the discharge from the afterburner (designated A2-18), and the discharge from the cooling stack on the afterburner (designated A2-19) Changes to Grain Handling Emission Points In the application for the review of the site s licence to accommodate the development of Brewhouse 4 and the associated works, a total of seven new emission points to atmosphere were identified. These emission points, located at the RMH Building adjacent to Brewhouse 4 on the Lower Level, were associated with the intake, handling and transfer of grains and gave rise to emissions of particulate matter. These emission points are listed in Table 2. Table 2: Emission Points at RMH Building (Application for Review of Licence P ) Emission Point Description Flow Rate (Nm 3 /h) Discharge Height (m) A2-10 Malt Line 1 33, A2-11 Malt Line 2 20, A2-12 Barley Line 3 20, A2-13 Rice Line 13, A2-14 Roast Barley Line 20, A2-15 Pale Dust Extraction 3, A2-16 Roast Dust Extraction 3, Emission points A2-15 and A2-16 are the air outlets from the cyclones on the extraction systems that transport the dust from grain hoppers inside the building to external skips. As can be seen from the table, the design data for A2-15 and A2-16 was based on a flow rate of 3,000 Nm 3 /h and a stack discharge height of 6.2 m above ground level, for each point. However, the as-installed design for 287-X0245 March 2015

15 Air Dispersion Modelling Study in Support of Application for Review of IE Licence 7 this equipment had a significantly lower flow rate (500 Nm 3 /h) with a discharge point adjacent to the cyclone at a height of 3.5 m above ground level. In addition to the design changes to the pale and roast dust extraction systems, an emission point associated with the rice blowing system was installed at the RMH building. The original design intent was to locate the cyclone within the building, with an internal discharge from the filter unit on the cyclone and hence an external emission point was not included at the time of the application for a licence review. However, in the final design of the RMH system, the rice dust cyclone was located on the roof of Brewhouse 4, at a discharge height of m above ground level. In light of these changes, the current arrangement of emission points to atmosphere associated with the grain intake & handling system at the RMH building is as summarised in Table 3. Table 3: Current Arrangement of Particulate Emission Points at RMH Building Emission Point Description Flow Rate (Nm 3 /h) Discharge Height (m) A2-10 Malt Line 1 33, A2-11 Malt Line 2 20, A2-12 Barley Line 3 20, A2-13 Rice Line 13, A2-14 Roast Barley Line 20, A2-15 Pale Dust Extraction A2-16 Roast Dust Extraction A2-17 Note 1 Rice Blowing Line Extraction 3, Note 1: Diageo proposes to designate the discharge from the rice blowing line extraction as main emission point A2-17, as described in the application for a review of licence P The air dispersion modelling scenarios that were carried out to assess the overall impact of these changes are set out in Section Site Environs The layout of the site is shown in Appendix A. It is located in Dublin City centre, bordered to the north by the River Liffey, to the south by Bond Street / Marrowbone Lane, to the west by Stevens Lane / Echlin Street and to the east by Watling Street / Crane Street / Bellevue. The site covers an area of approximately 24 hectares on either side of James s Street. The site to the south of St. James s Street is known as the Upper Level and the site to the north as the Lower Level. The two levels are connected by tunnels running under St. James s Street which convey production lines and services and provide pedestrian access between the two levels. The CHP plant is located on the Lower Level, to the east of the site adjacent to the boundary with Watling Street. Brewhouse 4 and the RMH building are also located on the Lower Level, close to the north boundary of the site at Victoria Quay. The elevation of the lowest point of the site, on the Lower Level at the boundary with Victoria Quay, is approximately 3 m AOD. There is a rise in elevation from the northern boundary of the Lower Level to the southern boundary with James s Street, at approximately 16 m AOD. The Upper Level varies in elevation from approximately 16 m AOD to 21 m AOD. 287-X0245 March 2015

16 Air Dispersion Modelling Study in Support of Application for Review of IE Licence 8 As the site is located within a city centre environment, there is a variety of land-use in the vicinity, including residential areas (primarily apartment buildings), commercial properties and offices, and parks / recreational areas (to the north of the River Liffey). Dr. Steeven s Hospital and St. Patrick s University Hospital are located to the west of the site (across Stevens Lane); Dr. Steeven s Hospital now serves as an administrative centre for the Health Service Executive. 3 DISPERSION MODELLING SCENARIOS 3.1 Overview This air dispersion modelling study has been conducted in support of the application for a licence review for the planned introduction of a fourth roasting plant and afterburner at the site. Two previous studies have been carried out in support of applications for the review of the licence to accommodate the installation of a third roasting plant (ref: BÓC report 287-X168) and Brewhouse 4 (ref. BÓC report 287-X0200). These studies assessed the environmental impact from each of the emission points identified in Table 4 and demonstrated that the impact from these emissions was not significant. The new main emissions to atmosphere arising from the introduction of the fourth roaster will discharge nitrogen oxides, total organics, and total particulate matter. In order to assess the incremental impact from the new emission points and the impact from the changes to the emission points at the RMH building, all boiler and main emissions across the site have been modelled as summarised in Table 4. Table 4: Emission Points and Modelled Emissions Emission Point Description Modelled Emission A1-3 CHP Boiler No. 1 NO X A1-4 CHP Boiler No. 2 NO X A1-5 CHP Boiler No. 3 NO X A1-6 Bypass Stack on Gas Turbine No. 1 NO X A1-7 CHP Boiler No. 4 NO X A2-1 Afterburner on Roaster No. 1 NO X, TOC A2-2 Afterburner on Roaster No. 2 NO X, TOC A2-3 Grain intake on Upper Level TPM A2-4 Grain intake on Upper Level TPM A2-5 Grain intake on Upper Level TPM A2-6 Afterburner on Roaster No. 3 NO X, TOC A2-7 Cooling stack on Roaster 1 TPM A2-8 Cooling stack on Roaster 2 TPM A2-9 Cooling stack on Roaster 3 TPM A2-10 Malt Line 1 at RMH Building TPM A2-11 Malt Line 2 at RMH Building TPM 287-X0245 March 2015

17 Air Dispersion Modelling Study in Support of Application for Review of IE Licence 9 Emission Point Description Modelled Emission A2-12 Barley Line 3 at RMH Building TPM A2-13 Rice Line at RMH Building TPM A2-14 Roast Barley Line at RMH Building TPM A2-15 / A3-75 Note 1 Pale Dust Extraction at RMH Building TPM A2-16 / A3-76 Note 1 Roast Dust Extraction at RMH Building TPM A2-17 Rice Blowing Line Extraction at RMH Building TMP A2-18 Afterburner on Roaster No. 4 NO X, TOC A2-19 Cooling stack on Roaster 4 TPM Note 1: Based on the concentration of particulate matter in the discharge from the pale and roast dust extraction points, the volumetric flow rate (and therefore the overall mass emission rate), and the results of this air dispersion modelling study, Diageo proposes to re-designate these two points as minor emission points, A3-75 and A3-76, respectively. 3.2 Nitrogen Oxides Emissions of nitrogen dioxide arise from the CHP plant and from the afterburners on the roasters. In order to assess the impact of the new afterburner, two modelling scenarios were carried out, as summarised in Table 5: Existing Operation: operation of the existing licensed emission points that discharge oxides of nitrogen at their respective licence limits (to establish the existing process contribution from the site); and Future Operation: operation of the existing licensed emission points (as per Scenario 1), plus operation of the new afterburner at the proposed licence limits (a flow rate of 8,000 Nm 3 /h and an NO X concentration of 75 mg/nm 3 (as NO 2 )). Table 5: Modelled Emissions of Nitrogen Oxides Emission Point Flow Rate (Nm 3 /h) Concentration (mg/nm 3 ) Existing Operation Future Operation A1-3 62, A1-4 62, A1-5 62, A1-6 62, A1-7 23, A2-1 5, A2-2 5, A2-6 8, A2-18 8, X0245 March 2015

18 Air Dispersion Modelling Study in Support of Application for Review of IE Licence Total Organics Emissions of total organics arise from the afterburners on the roasters. In order to assess the impact of the new afterburner, two modelling scenarios were carried out, as summarised in Table 6: Existing operation: operation of the existing licensed emission points that discharge total organics at their respective licence limits (to establish the current process contribution from the site); and Future Operation: operation of the existing licensed emission points (as per Scenario 1), plus operation of the new afterburner at the proposed licence limits (a flow rate of 8,000 Nm 3 /h and a TOC concentration of 50 mg/nm 3 ). Table 6: Modelled Emissions of Total Organics (as C) Emission Point Flow Rate (Nm 3 /h) Concentration (mg/nm 3 ) Existing Operation Future Operation A2-1 5, Note 1 A2-2 5, Note 1 A2-6 8, A2-18 8, Note 1: The licence limits for Total Organics for A2-1 and A2-2 are expressed in terms of kilograms per hour (0.2 kg/h and 0.4 kg/h, respectively). These have been converted to their equivalent mass concentrations at the licensed volumetric flow rate. 3.4 Particulate Matter Overview The existing emissions of total particulate matter arise from the grain intake filters on the Upper Level, from the three cooling stacks on the existing afterburners on the Upper Level, and from the grain intake area and grain / dust handling system at the RMH building on the Lower Level. The following configurations have been modelled: 1. the current configuration of the licensed emission points, taking into account the changes to the pale and roast dust emission points (the reduction in mass emission); 2. the current configuration, plus the introduction of the rice dust emission point; 3. the current configuration, plus the operation of the cooling stack associated with the fourth roaster; and 4. the future configuration, incorporating all changes (the pale & roast dust emission points, the introduction of the rice dust emission point, and the cooling stack associated with the fourth roaster) Particulate Matter Size Distribution As set out in the previous air dispersion modelling studies (BÓC reports 287-X0168 and ), Diageo has carried out an assessment to characterise the size distribution of the particulate matter emissions from both the grain handling activities and the cooling stacks on the roasters. The size 287-X0245 March 2015

19 Air Dispersion Modelling Study in Support of Application for Review of IE Licence 11 profile for the dust from the cooling stacks on the afterburners is shown in Figure 5 and from the dust filters is shown in Figure 6. Figure 5: Cumulative Distribution of Particle Size from Cooling Stacks 100% Cumulative Particle Size Distribution - Afterburner Coolers 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% ,000 10,000 Particle Size (mm) Figure 6: Cumulative Distribution of Particle Size from Grain Handling Systems 100% Cumulative Particle Size Distribution - Dust Filters 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% ,000 10,000 Particle Size (mm) The size profiles are summarised in Table X0245 March 2015

20 Air Dispersion Modelling Study in Support of Application for Review of IE Licence 12 Table 7: Summary of Particulate Matter Size Profile Particle Size Grain Handling Emission Points Cooling Stack Emission Points Total Particulate 100% 100% PM 10 19% 32% PM % 4.2% Modelled Emissions Table 8 summarises the inputs to the model for particulate matter. Table 8: Modelled Emissions of Particulates Emission Point Flow Rate (Nm 3 /h) Total Particulate Matter Concentration (mg/nm 3 ) PM 10 PM 2.5 A2-3 28, A2-4 24, A2-5 14, A2-7 15, A2-8 15, A2-9 15, A , A , A , A , A , A2-15 / A A2-16 / A A2-17 3, A , X0245 March 2015

21 Air Dispersion Modelling Study in Support of Application for Review of IE Licence 13 4 DISPERSION MODEL 4.1 Modelling Programmes The following proprietary software packages were used to conduct and assess the air dispersion modelling: BREEZE AERMOD, a dispersion modelling system that simulates essential atmospheric physical processes and provides refined concentration estimates over a wide range of meteorological conditions and modelling scenarios. Ground level concentrations are determined for specified averaging periods; e.g. 8-hour. BREEZE AERMAP, a terrain pre-processor used to prepare the terrain information required by AERMOD for complex terrain scenarios. BREEZE BPIP (Building Profile Input Programme), which is used to model the effects of building downwash on the emission from the stack. BREEZE 3D Analyst, a post-processing package used to analyse the raw data from the dispersion modelling programme. The latest versions of each of the modelling packages were used. The model was run for the scenarios as described in Section Input Data Site Buildings & Structures The length, width, height and the co-ordinates of the buildings and building structures across the site, in particular in the vicinity of the CHP plant, the roasthouse and afterburner stacks, the Robert St. Building, and Brewhouse 4 and the RMH Building, were entered into the model. In addition, large off-site buildings with the potential to impact on the building downwash were entered into the model, including the buildings on Watling Street Emissions & Emission Rates As outlined in Section 3, this report examines the impacts of emissions of nitrogen oxides, total organics, and particulate matter to atmosphere. Table 5, Table 6 and Table 8 in Sections 3.2, 3.3 and 3.4, respectively, provide details of the emissions and emission rates for each of the model scenarios for each of the substances Emission Durations & Frequencies As set out in the EPA s guidance, each of the emission points has been modelled on the basis of 24 hour per day, 365 day per year operation as each of the emission points could be operational at any time of the year. However, in practice, the emission points do not operate on a continuous basis for 365 days of the year. In particular, the discharges of particulate matter from the emission points associated with the grain handling system only occur when grain is being transferred. In the case of current emission points A2-15 and A2-16, the cumulative discharge duration is typically no more than 2 hours per day. In the case of the new emission point associated with the rice blowing system (A2-17), the discharge duration is typically 1½ hours per day, one day per week. 287-X0245 March 2015

22 Air Dispersion Modelling Study in Support of Application for Review of IE Licence Stack Heights The actual stack heights of the afterburners, cooling stacks, CHP stacks and grain intake / handling emission points were used in the model, except for the two current emission points associated with the pale and roast dust extraction system (A2-15 and A2-16). These two emission points are oriented downwards, discharging into dedicated collection skips located at the adjacent to the cyclones. In order to model the emissions from these two points, the effective release height was calculated based upon the approach set out in HMIP Technical Guidance Note D1 Dispersion Meteorological Data The EPA s guidance requires a minimum of three years of meteorological data to be used, with the most recent year of the three year dataset to be within ten years of the date of the dispersion modelling study. The meteorological data from Dublin Airport, which is the closest Met Éireann weather station to the site, for the three years from 2008 to 2010, has been used in this modelling study. The wind roses for this weather station for the three years are included in Appendix B to this study Digital Terrain Data Digital terrain data for the site and the surrounding area was provided by the Ordnance Survey of Ireland on a 10 m grid. The elevations of each co-ordinate of the model grid were extracted from this data and entered into the model via the AERMAP pre-processor. Buildings entered in the model at specific co-ordinates were automatically assigned an elevation based on the terrain data Receptor Points Two Cartesian grids of receptor points around the site and its environs were set up in the model. The first grid (Grid 1) extended a minimum of 750 m in each direction from the perimeter of the site, while the second grid (Grid 2) was set at a finer resolution in the immediate vicinity of the site. Table 9 provides the details for the two grids. Table 9: Grids and Receptor Points Grid 1 Grid 2 Length 5,000 m Length 1,000 Width 5,000 m Width 1,150 Grid Line Interval 250 m Grid Line Interval 50 m Number of Receptor Points 441 Number of Receptor Points 504 The grid used in the model contained the maximum ground level concentrations all of the modelled parameters. It extends beyond the site boundary to each of the neighbouring areas described in Section X0245 March 2015

23 Air Dispersion Modelling Study in Support of Application for Review of IE Licence NO 2 / NO X Chemistry The EPA s guidance notes that during combustion processes, a mixture of both nitric oxide (NO) and nitrogen dioxide (NO 2 ) is released to atmosphere, following which a series of chemical reactions take place. During these reactions, a portion of the nitric oxide reacts with ozone (O 3 ) is converted to nitrogen dioxide. In turn, nitrogen dioxide can react with sunlight to form nitric oxide and ozone, with the reactions ultimately resulting in a quasi-equilibrium ratio of NO 2 to NO X. There are a number of methods available within AERMOD to model the dispersion of oxides of nitrogen. The EPA s guidance notes that the Plume Volume Molar Ratio Method (PVMRM) shows better agreement with monitoring data than the other options in AERMOD, and therefore this method was selected in the air dispersion modelling study. The input parameters required for the PVMRM are: the background concentration of ozone (O 3 ) (refer to Section 4.3.2); the NO 2 / NO X equilibrium ratio (0.9); and the in-stack NO 2 / NO X ratio (0.1). 4.3 Background Concentrations Overview In order to assess the overall contribution of the emissions to atmosphere from a site in the context of the Air Quality Standard (or guidance value), the background concentration of the particular parameter must also be considered. The EPA maintains a number of ambient monitoring stations throughout the country for a range of parameters, which record background data on an hour-byhour or a day-by-day basis. The EPA provides guidance on the methods for combining the predicted process contribution with the available background data in order to calculate the overall predicted environmental concentration (PEC). It is conservatively assumed that the maximum background concentration from a particular station overlaps spatially with the maximum predicted process contribution, and therefore it is appropriate to use such background data for the purpose of estimating the PEC. It is also assumed that the background concentrations will be greatest during stable atmospheric conditions. Where the maximum predicted process contribution also occurs during periods of stable atmospheric conditions, it is necessary to adopt a conservative approach to combine the process contribution and the background contribution. One method for combining these data, as identified by the EPA, is that set out in the UK Department for Environment and Rural Affairs (DEFRA) Local Air Quality Management Technical Guidance document. The methods for estimating the total contribution of nitrogen dioxide and particulate matter (for which DEFRA and the Environment Agency have produced guidance) are set out in Sections and 4.3.5, respectively. In terms of accounting for the contribution of existing emissions on the background concentrations, the EPA s guidance notes that monitoring is not an effective method to obtain information on the impact of an existing industrial installation, particularly when emissions are mainly from stacks. In light of this the background concentrations of the parameters are conservatively assumed not to include the existing contribution from the site. 287-X0245 March 2015

24 Air Dispersion Modelling Study in Support of Application for Review of IE Licence Ozone As noted in Section 4.2.8, modelling the dispersion of oxides of nitrogen requires details of the background concentration of ozone. The closest EPA monitoring stations to the site that record such concentrations are in Rathmines and Clonskeagh, with the results for the last three years of available data shown in Table 10. Table 10: Summary of Annual Average Ozone Background Data from EPA Monitoring Stations Period Rathmines (mg/m 3 ) Clonskeagh (mg/m 3 ) year average The average of four background concentrations (47 mg/m 3 ) has been entered in the PVMRM method (Plume Volume Molar Ratio Method) in the AERMOD model, as set out in the EPA s guidance Nitrogen Oxides Annual Average Historically, there have been two sources of background data for nitrogen dioxides in the vicinity of the site: the data from the EPA s air quality monitoring programme for the Winetavern Street and Coleraine Street monitoring stations, and the data from the site s former monitoring station located at the main office on St. James s Street 1. The background data for 2011 to 2013 for the two EPA monitoring stations is summarised in Table 11 and shown graphically in Appendix C. As described in detail in the previous application for a review of the licence to accommodate the installation of the third roaster, the results from the site s monitoring station were consistent with those of the EPA s monitoring stations. Table 11: Summary of Annual Average NO 2 Background Data from Monitoring Stations Period Winetavern Street NO 2 (µg/m 3 ) Coleraine Street year average For the purpose of this study, the higher annual average background concentration of 28.8 mg/m 3 has been used when assessing the results (described in Section 6.2). 1 Monitoring at the former background monitoring station ceased in 2012 with the consent of the EPA. 287-X0245 March 2015

25 Air Dispersion Modelling Study in Support of Application for Review of IE Licence th Percentile Table 12: Summary of Annual Average NO 2 Background Data from Monitoring Stations Period Winetavern Street NO 2 (µg/m 3 ) Coleraine Street year average For the purpose of this study, the higher 1-hour, 99.8 th percentile background concentration of mg/m 3 has been used when assessing the results (described in Section 6.2) Total Organics The EPA does not maintain monitoring stations to monitor for background (ambient) total organics, and therefore background concentrations have not been included within this study Particulate Matter There is no background monitoring data for total particulate matter. However, the EPA monitors for PM 10 at its monitoring station at Winetavern Street and PM 2.5 at its monitoring station at Coleraine Street. As the total particulate matter emitted to atmosphere from the various stacks at the site includes particulates larger than 10 microns (and 2.5 microns), it is not appropriate to assess the results of the model for total particulate matter emissions in the context of background PM 10 or PM 2.5 data (grain dust typically contains in the order of 20% to 30% PM 10 and 4% PM 2.5, although this can vary depending upon the source of the material). In order to assess the significance of the impact of emissions of total particulate matter in the vicinity of the site, emissions of PM 10 and PM 2.5 have also been modelled. Table 13 summarises the background monitoring data at the EPA s two monitoring stations closest to the site. Table 13: Summary of Annual Average Particulate Matter Background Data from EPA Monitoring Stations Period PM 10 Winetavern Street (µg/m 3 ) Period PM 2.5 Coleraine Street (µg/m 3 ) year average year average 10.9 As in the case of nitrogen dioxide, the total contribution of PM 10 (background and process) has been estimated using the method set out in the EPA s guidance document. Using this approach, the 90.4 th percentile of total 24-hour mean PM 10 is equal to the maximum of: 287-X0245 March 2015

26 Air Dispersion Modelling Study in Support of Application for Review of IE Licence 18 (a) 90.4 th percentile 24-hour mean background PM 10 + annual mean process contribution or (b) 90.4 th percentile 24-hour mean process contribution PM 10 + annual mean background PM 10 There is no 24-hour limit value for PM 2.5 and therefore this approach does not apply for PM Modelling Outputs The BPIP programme was run to calculate the building downwash for each scenario. The AERMOD programme was then run to calculate the resultant ground-level concentrations (raw data) for each of the receptor points over each of the three years of meteorological data for each of the scenarios. The raw data from AERMOD was subsequently analysed in 3DAnalyst. The relevant maximum concentrations for each receptor point for each of the three years over which the model was run were extracted from this raw data. These results are assessed in Section 6 against the criteria described in Section 5. 5 ASSESSMENT CRITERIA 5.1 Nitrogen Oxides The results of the air dispersion model, including the contribution of the background concentrations, were assessed in the context of the Air Quality Standards Regulations, 2011 (SI 180 of 2011). Schedule 11 of the Regulations sets out the limit values for the protection of human health for nitrogen dioxide, shown in Table 14. Table 14: Limit Values for the Protection of Human Health Nitrogen Dioxide Averaging Period Limit Value Date by which limit is to be met One hour 200 µg/m 3, not to be exceeded more than 18 times a calendar year 1 January 2010 Calendar year 40 µg/m 3 1 January Total Organics Air Quality Guidelines While Air Quality Guidelines (AQGs) have been developed for a variety of air pollutants, including nitrogen dioxides and PM 10, the Air Quality Regulations (2011) do not include air quality standards for TOC. The EPA s guidance (AG4) identifies the sources of data to consider when determining compliance in the absence of a published air quality standard. These references include: Danish C-values (as a 99 th %ile) outlined in Danish EPA s Environmental Guidelines No. 1, 2002 Guidelines for Air Emission Regulation Limitation of air pollution from installations. Instructions on Air Quality Control TA Luft from the German Federal Ministry for the Environment, Nature Conservation and Nuclear Safety Technical 287-X0245 March 2015

27 Air Dispersion Modelling Study in Support of Application for Review of IE Licence 19 Environmental Assessment Level (EAL) based on the Health & Safety Authority publication 2007 Code of Practice for the Safety, Health and Welfare at Work (Chemical Agents) Regulations 2001 (S.I. No. 619 OF 2001). The EAL should be derived using the approach outlined in Appendix D of UK Environment Agency IPPC H1 - IPPC Environmental Assessment for BAT Appendix D of the UK Environment Agency IPPC H1 - IPPC Environmental Assessment for BAT (Environment Agency, 2003) World Health Organisation (WHO) Air Quality Guidelines Global Update (2005) and WHO Air Quality Guidelines For Europe (2000) The method set out in the Health and Safety Authority s Code of Practice, together with the Environmental Assessment Level approach outlined in the UK Environment Agency s H1 guidance has been applied to the results from the dispersion model to assess the significance of the impact. The guidance set out by the Danish EPA and the German Federal Ministry have also been applied HSA Code of Practice & UK EA Guidance The method referred to in the Environment Agency s 2003 edition of its H1 guidance was updated in 2008 and again in Annex F of the latest version of the H1 guidance document sets out the method for assessing the impact of emissions to atmosphere based upon EALs derived from the occupational exposure limits for the individual parameters. Monitoring of emissions from the afterburner when it was operated at the Diageo Waterford Brewery showed the presence of thirteen organic parameters (see Table 15). The derived EALs for these organic compounds are based upon their respective occupational exposure limits from the Health and Safety Authority s 2011 Code of Practice for the Safety, Health and Welfare at Work (Chemical Agents) Regulations 2001 (one-hundredth of the 8-hour occupational exposure level). Table 15: Concentration of Individual Parameters in Emission Parameter Stack Concentration (mg/m 3 ) Acetone Acrylonitrile Benzene Chloroform 0.02 Chloromethane Hexamethylcyclotrisiloxane 0.82 Methyl Acetate Methyl Ethyl Ketone Octamethylcyclotetrasiloxane 5.6 Tetrakis(trimethylsiloxy)silane 0.27 Trimethyl Silanol Trimethylsilyl-2((Trimethylsilyl)oxy)benzoate 1.4 Trimethylsilyl-2((Trimethylsilyl)oxy)phenyl acetate X0245 March 2015

28 Air Dispersion Modelling Study in Support of Application for Review of IE Licence 20 The HSA s Code of Practice does not list short term occupational exposure levels for any of the parameters in the emission to atmosphere. Although the Environment Agency s guidance permits the use of the long term occupational exposure limit to derive short term EALs, it provides data on short term EALs for a number of these parameters. In such cases, we have used the short term EAL from the guidance, rather than deriving a figure based on published occupational exposure levels. The long and short term derived EALs, taken from the HSA s Code of Practice and the Environment Agency s H1 Guidance, respectively, are shown in Table 16. In the case of six of the parameters (identified with an asterisk), no occupational exposure limits have been established (for either long term or short term exposure). Adopting a conservative approach, as indicated in the Agency s guidance, the predicted ground level concentrations for these parameters have been assessed against the Air Quality Standard for benzene (5 µg/m 3 on an annual average basis). Table 16: Individual Parameter Concentrations & as a Percentage of Total TOC Parameter Long Term EAL (annual average) (mg/m 3 ) Note 1 Short Term EAL (1-hour average) (mg/m 3 ) Note 2 Acetone Acrylonitrile Benzene Note 3 n/a Chloroform Chloromethane Note 4 Note 4 Hexamethylcyclotrisiloxane* Methyl Acetate Methyl Ethyl Ketone Note 4 Note 4 Octamethylcyclotetrasiloxane* Note 4 Note 4 Tetrakis(trimethylsiloxy)silane* Note 4 Note 4 Trimethyl Silanol* Note 4 Note 4 Trimethylsilyl-2((Trimethylsilyl)oxy)benzoate* Note 4 Note 4 Trimethylsilyl-2((Trimethylsilyl)oxy)phenyl acetate* Note 1: Based on the 8-hour occupational exposure limits set out in the HSA guidance. Note 2: Provided in the Environment Agency s H1 Guidance. Note 3: An Air Quality Standard of 5 µg/m 3, on an annual average basis, has been established for benzene. Note 4: No occupational exposure limits have been established for these parameters. A long term EAL of 5 µg/m 3, on an annual average basis has been applied for the purpose of this analysis The HSA s Code of Practice provides a method for calculating the combined effect of multiple parameters in the context of their occupational exposure limits. This method can be applied to assess the combined effect of multiple parameters on the overall air quality, using the following equation: 287-X0245 March 2015

29 Air Dispersion Modelling Study in Support of Application for Review of IE Licence 21 GLC i is the ground level concentration of parameter i, and EAL i is the corresponding Environmental Assessment Level for parameter i. Where this sum is greater than 1 (or 100%), the combined EAL has been exceeded Danish C-Values The Danish EPA s Guidelines for Air Emission Regulation define the C-value as: the total maximum permissible contribution from a single installation of one pollutant to the surrounding air, i.e. the ground-level concentration. For TOC, the Danish guidelines set a C-value of 0.1 mg/m 3, which has been applied in this Air Dispersion Modelling study and in the assessment of the results. This is equivalent to the S-value set out in the T.A. Luft Guidelines (refer to Section 5.2.4) TA Luft S-Values The T.A. Luft Guidelines, originally published in 1986, were substantially revised in In T.A. Luft 2002, emission limit values (concentration in mg/m 3 ) and threshold mass flow rates are assigned to individual classes of substances. T. A. Luft also contains immission values, which correspond with the level of a pollutant that may be present in the air outside a plant. It is usually taken at 1.5 m above ground level. The immission values in T.A. Luft are limited to a few pollutants. However, T.A. Luft lists S-values for a variety of classes of pollutants. These S-values are dimensionless factors which are used in the method presented in the instructions for calculating discharge stack heights. Since S-values are effectively related to ground level concentrations in mg/m 3, they are sometimes used as air quality guidelines in the absence of established standards. We have previously discussed the use of S-values as air quality guidelines with the EPA and were advised that such an approach would be acceptable to the EPA. An S-value from T.A. Luft for TOC would be 0.1. This value, taken in units of mg/m 3, is used as a derived AQG in the assessment of the emissions of TOC from the afterburners. Since there is no specific guidance given on the emission limits for TOC or on the appropriate percentile to use, we have applied the 99 th percentile (the value that is not exceeded for more than 88 hours per year), which is the percentile called up in the Danish Environmental Protection Agency s Industrial Air pollution Control Guidelines WHO Guidelines The WHO Air Quality guidelines were originally published in 1987 and were revised in They contain a number of guideline values for the European region for both organic and inorganic substances. In 2005, the WHO published updated values for particulate matter, ozone, nitrogen dioxide and sulphur dioxide, applicable globally and replacing the guideline values for these parameters contained in the 2000 Air Quality Guidelines for Europe. The primary aim of the guidelines is to provide a basis for protecting public health from adverse effects of air pollution and for eliminating, or reducing to a minimum, those contaminants of air that are known or likely to be hazardous to human health and wellbeing. 287-X0245 March 2015

30 Air Dispersion Modelling Study in Support of Application for Review of IE Licence 22 The guidelines are intended to provide background information and guidance to governments in making risk management decisions, particularly in setting standards, but their use is not restricted to this. They also provide information for all who deal with air pollution. However, there is no WHO guideline value for TOC. 5.3 Particulate Matter The results of the air dispersion model, including the contribution of the background concentrations, were assessed in the context of the Air Quality Standards Regulations, 2011 (SI 180 of 2011). Schedule 11 of the Regulations sets out the limit values for the protection of human health for Particulate Matter (as PM10), shown in Table 13. Schedule 14 of the Regulations sets out target and limit values for Particulate Matter (as PM2.5) and these are shown in Table 14. As noted in Section 3.4.2, the Total Particulate Matter discharged from the emission points at the site consists of PM 2.5, PM 10 and larger particle sizes. Therefore, comparison of the results from the dispersion model against PM 2.5 or PM 10 assessment criteria is not appropriate. In order to assess the impact of particulate emissions, the PM 10 and PM 2.5 results have been compared against the corresponding Air Quality Standards assessment criteria, as set out in Table 17 and Table 18, respectively. Table 17: Limit Values for the Protection of Human Health Particulate Matter as PM 10 Averaging Period One day Limit Value 50 µg/m 3, not to be exceeded more than 35 times a calendar year Calendar year 40 µg/m 3 Table 18: Limit Values for the Protection of Human Health Particulate Matter as PM 2.5 Averaging Period Target / Limit Value Date Calendar year 25 µg/m 3 to 31 December µg/m 3 from 1 st January 2015 Note: The PM 2.5 value of 25 mg/m 3 is currently a Target Value. In 2015 it will be reduced to 20 mg/m 3 as a Limit Value. 6 ASSESSMENT OF RESULTS 6.1 Introduction The results from the air dispersion models for nitrogen oxides, total organics and particulate matter are summarised in the following subsections. The plots showing the impacts to the surrounding area are shown in the contour maps in Appendix D. In assessing the results from the model, the highest off site ground level concentrations have been used. As shown in the contour maps in Appendix D, the highest concentrations occur in close proximity to the site, with the concentrations at adjoining sites significantly less than the highest off site ground level concentrations. 287-X0245 March 2015

31 Air Dispersion Modelling Study in Support of Application for Review of IE Licence Nitrogen Oxides Modelling Results The dispersion modelling results for nitrogen oxides are shown in Table 19 for the 99.8 th percentile process contribution and in Table 20 for the annual average process contribution. Table 19: 99.8 th Percentile NO 2 Process Contribution (µg/m 3 ) Year Current Future Highest Table 20: Annual Average NO 2 Process Contribution (µg/m 3 ) Year Current Future Highest Ground Level Concentration In assessing the combination of the short-term (1-hour) ground level concentrations of nitrogen dioxide and the background concentrations from the EPA s monitoring station, the approach set out in Appendix E from the EPA s guidance has been adopted. Using this approach, the 99.8 th percentile of total nitrogen dioxide is equal to the minimum of: th percentile hourly background total oxidant (O 3 & NO 2 ) plus th percentile process contribution or the maximum of 2. (i) 99.8 th percentile process contribution NO X + 2 annual mean background NO 2, OR (ii) 99.8 th percentile hourly background NO annual mean process contribution NO X Combining the results from the background monitoring for nitrogen dioxide and for ozone (from the EPA s monitoring stations) yields the total background concentration of oxidant required in the calculation outlined above (part (a)). The calculations for (b)(i) and (b)(ii) are based upon the results from the Air Dispersion model, summarised in Table X0245 March 2015

32 Air Dispersion Modelling Study in Support of Application for Review of IE Licence 24 Table 21: Calculation of 99.8 th percentile Total NO 2 (Process Contribution plus Background) (µg/m 3 ) Step Description Current Future th %ile hourly background total oxidant (NO 2 + O 3 ) th %ile hourly background NO Annual mean background NO Highest 99.8 th %ile process contribution NO Highest 99.8 th %ile process contribution NO X Highest annual mean process contribution NO Highest annual mean process contribution NO X Calculation (a) (1) (5) Calculation (b)(i) (5) + 2 (3) Calculation (b)(ii) (2) + 2 (7) Calculated 99.8 th %ile total NO Air Quality Standard The results from this calculation show that the 99.8 th percentile total ground level concentration of nitrogen dioxide, taking into account both the process contribution and the background contribution, does not exceed the 1-hour ambient air quality standard of 200 µg/m 3. Furthermore, the total ground level concentration is less than 75% of the air quality guidance value and therefore, as indicated in Appendix E to the EPA s guidance document, a more detailed investigation is not required to assess the impact of the short term emissions of nitrogen dioxide from the site. In addition to calculating the 99.8 th percentile total ground level concentration, the annual average ground level concentration of nitrogen dioxide is also assessed in the context of the background concentrations of NO 2. The results of this assessment are summarised in Table 22. Table 22: Annual Average Predicted Environmental Contribution of NO 2 (µg/m 3 ) Description Current Future Process contribution (PC) Background concentration (BC) Predicted Environmental Contribution (PEC) Air Quality Standard (AQS) The maximum allowable process contribution, calculated in accordance with the method set out in the EPA s guidance, yields a maximum allowable process contribution of 7.5 µg/m 3. As can be seen from the results in Table 22, the total predicted environmental contribution from both the current activities at the site and from the future activities with the operation of the fourth roaster and afterburner, are less than the air quality standard. The process contributions from the current and future activities are also less than the maximum allowable process contributions. 287-X0245 March 2015

33 Air Dispersion Modelling Study in Support of Application for Review of IE Licence Total Organics Modelling Results The results from the air dispersion model for each of the three individual years are summarised in Table 23 in terms of the 99 th percentile, 1-hour ground level concentration of total organics (as C). Table 23: 99 th Percentile, 1-hour Ground Level Total Organics Concentration (mg/m 3 ) Year Current Future Highest The highest predicted 99 th percentile, 1-hour ground level concentration for total organics from the model is mg/m 3 for the future operations at the site (with the fourth roaster and afterburner operating), which occurs under the meteorological data for The annual average ground level concentrations of TOC were also calculated for the same three individual years. The results were used when calculating the ground level concentrations of the various organic constituents in the emission for comparison with the long term EAL values. The results are summarised in Table 24. Table 24: Annual Average Ground Level Total Organics Concentration (mg/m 3 ) Year Current Future Highest Ground Level Concentrations As required under the EPA s guidance, in assessing the process contribution (PC) from the site against the overall ambient air quality standard (derived Air Quality Guideline), the maximum allowable process contribution has been calculated as follows: In the absence of background concentrations of total organics, the maximum allowable process contribution from the site has been calculated at two-thirds of the derived AQG (0.1 mg/m 3 ), namely mg/m 3. The maximum ground level concentration (expressed in terms of the 99 th percentile, 1-hour concentration) predicted from the model is mg/m 3, which is less than 44% of the maximum allowable process contribution. The results of this analysis are shown in Appendix E. 287-X0245 March 2015

34 Air Dispersion Modelling Study in Support of Application for Review of IE Licence Organic Constituents In addition to examining TOC, the individual constituents in the emission have been compared against the corresponding short-term and long-term environmental assessment levels (EAL) (refer to Table 16). These results are summarised in Table 25 and Table 26. Table 25: Comparison of Annual Ground Level Concentrations with Long Term EAL Values (mg/m 3 ) Parameter Current Future Annual GLC GLC as % of EAL Annual GLC GLC as % of EAL Acetone % % Acrylonitrile % % Benzene % % Chloroform % % Chloromethane % % Hexamethylcyclotrisiloxane* % % Methyl Acetate % % Methyl Ethyl Ketone % % Octamethylcyclotetrasiloxane* % % Tetrakis(trimethylsiloxy)silane* % % Trimethyl Silanol* % % Trimethylsilyl- 2((Trimethylsilyl)oxy)benzoate* Trimethylsilyl- 2((Trimethylsilyl)oxy)phenyl acetate* % % % % * EAL value for Benzene has been applied for these parameters Table 26: Comparison of 1-hr Ground Level Concentrations with Short Term EAL values (mg/m 3 ) Parameter 99 th % 1-hour GLC Current GLC as % of EAL 99 th % 1-hour GLC Future GLC as % of EAL Acetone % % Acrylonitrile % % Benzene Chloroform % % Chloromethane % % Hexamethylcyclotrisiloxane X0245 March 2015

35 Air Dispersion Modelling Study in Support of Application for Review of IE Licence 27 Parameter 99 th % 1-hour GLC Current GLC as % of EAL 99 th % 1-hour GLC Future GLC as % of EAL Methyl Acetate % % Methyl Ethyl Ketone % % Octamethylcyclotetrasiloxane Tetrakis(trimethylsiloxy)silane Trimethyl Silanol Trimethylsilyl- 2((Trimethylsilyl)oxy)benzoate Trimethylsilyl- 2((Trimethylsilyl)oxy)phenyl acetate In each case the results are significantly lower than the EAL values. As outlined in Section 5.2.2, many of the parameters contributing to the TOC emission do not have EAL value published for them and so we conservatively applied the Long Term AQS for Benzene (5 µg/m 3 on an annual average basis) to those other parameters in order to assess the overall impacts of the emissions using the HSA s equation: Even using this conservative approach, the overall calculation for these emissions works out as 0.58 (using the data in Table 32), which is less than 1, which means that the combined EAL has not been exceeded, using the HSA s method. 6.4 Particulate Matter Overview As outlined in Section 3.4, particulate matter emissions from the site have been modelled as total particulate matter, as PM 10 and as PM 2.5. The results for total particulate matter are summarised in Section 6.4.2, the results for PM 10 are summarised in Section and the results for PM 2.5 are summarised in Section 6.4.4, each taking into account the background concentrations of these parameters, where applicable. As set out in Section 3.4, the following configurations have been modelled in the context of particulate matter: 1. the current configuration of the licensed emission points, taking into account the changes to the pale and roast dust emission points (the reduction in mass emission); 2. the current configuration, plus the introduction of the rice dust emission point; 3. the current configuration, plus the operation of the cooling stack associated with the fourth roaster; and 4. the future configuration, incorporating all changes (the pale & roast dust emission points, the introduction of the rice dust emission point, and the cooling stack associated with the fourth roaster). 287-X0245 March 2015

36 Air Dispersion Modelling Study in Support of Application for Review of IE Licence Total Particulate Matter Table 27 and Table 28 summarise the maximum 90.4 th percentile daily and the annual average off site ground level concentrations of total particulate matter as a result of the emissions from the grain intake filters on the Upper Level, the cooling stacks on the afterburners on the Upper Level, and the particulate emission points associated with the RMH Building and Brewhouse 4 for the four configurations. Table 27: 90.4 th Percentile Daily Total Particulate Matter Process Contribution (mg/m 3 ) Year Configuration 1 Configuration 2 Configuration 3 Configuration Highest Table 28: Annual Average Total Particulate Matter Process Contribution (mg/m 3 ) Year Configuration 1 Configuration 2 Configuration 3 Configuration Highest Particulate Matter as PM Modelling Results Table 29 and Table 30 summarise the maximum 90.4 th percentile daily and the annual average off site ground level concentrations of particulate matter as PM 10 as a result of the emissions from the grain intake filters on the Upper Level, the cooling stacks on the afterburners on the Upper Level, and the particulate emission points associated with the RMH Building and Brewhouse 4 for the four configurations. Table 29: 90.4 th Percentile Daily PM 10 Process Contribution (mg/m 3 ) Year Configuration 1 Configuration 2 Configuration 3 Configuration Highest X0245 March 2015

37 Air Dispersion Modelling Study in Support of Application for Review of IE Licence 29 Table 30: Annual Average PM 10 Process Contribution (mg/m 3 ) Year Configuration 1 Configuration 2 Configuration 3 Configuration Highest Ground Level Concentrations Applying the calculation method for combining short term, ground level process contributions with long term background concentrations of PM 10 as set out in Section (and Appendix E of the EPA s guidance), yields the total contributions of PM 10 as summarised in Table 31. Table 31: Calculation of 90.4 th percentile PM 10 (Process Contribution plus Background) (μg/m 3 ) Total Site Description Configuration 1 Configuration 2 Configuration 3 Configuration th %ile 24-hour mean background PM Annual mean background PM th %ile 24-hour mean process contribution PM 10 4 Annual mean process contribution PM Calculation (a): (1) + (4) Calculation (b): (2) + (3) Calculated 90.4 th % total 24-hour mean The results shown in Table 31 are obtained from the outputs from the air dispersion model and the calculations set out in Section The results from this calculation show that the 90.4 th percentile total ground level concentration of PM 10, taking into account both the process contribution and the background contribution, do not exceed the daily air quality standard of 50 μg/m 3 for any of the configurations. Furthermore, the total ground level concentration is less than 75% of the air quality guidance value and therefore, as indicated in Appendix E to the EPA s guidance, a more detailed investigation is not required to assess the impact of the short term emissions of PM 10 from the site. In addition to calculating the 90.4 th percentile total ground level concentration of PM 10, the annual average ground level concentration of PM 10 is also assessed in the context of the background concentrations for these parameters. The results of this assessment are summarised in Table X0245 March 2015

38 Air Dispersion Modelling Study in Support of Application for Review of IE Licence 30 Table 32: Annual Average Predicted Environmental Contribution of PM 10 (mg/m 3 ) Description Configuration 1 Configuration 2 Configuration 3 Configuration 4 Process contribution (PC) Background concentration (BC) Predicted Environmental Contribution (PEC) Air Quality Standard The maximum allowable process contribution, calculated in accordance with the method set out in the EPA s guidance, yields a maximum allowable process contribution of 17.7 μg/m 3, based upon the average of the annual average background concentrations of PM10 over the last three years (2008 to 2010). As can be seen from the results, the process contribution is significantly less that the maximum allowable process contribution Particulate Matter as PM Modelling Results Table 33 summarise the annual average off site ground level concentrations of particulate matter as PM 2.5 as a result of the emissions from the grain intake filters on the Upper Level, the cooling stacks on the afterburners on the Upper Level, and the particulate emission points associated with the RMH building and Brewhouse 4 for the four configurations. Table 33: Annual Average PM 2.5 Process Contribution (mg/m 3 ) Year Configuration 1 Configuration 2 Configuration 3 Configuration Highest X0245 March 2015

39 Air Dispersion Modelling Study in Support of Application for Review of IE Licence Ground Level Concentrations The annual average ground level concentration of PM 2.5 is assessed in the context of the background concentration. The results of this assessment are summarised in Table 34. Table 34: Annual Average Predicted Environmental Contribution (mg/m 3 ) Description Configuration 1 Configuration 2 Configuration 3 Configuration 4 Process contribution (PC) Background concentration (BC) Predicted Environmental Contribution (PEC) Air Quality Standard The maximum allowable process contribution, calculated in accordance with the method set out in the EPA s guidance, yields a maximum allowable process contribution of 10.2 μg/m 3, based upon the average of the annual average background concentrations of PM 2.5 over the last three years (2010 to 2012). As can be seen from the results, the process contribution is significantly less that the maximum allowable process contribution. 6.5 Cumulative Impact Assessment Overview In accordance with Section 6.6 and Appendix F of the EPA s guidance, the requirement for a cumulative impact assessment has been examined as part of this study, as set out in the following sections Impact Area The first stage in determining whether a cumulative assessment is required is to determine the impact area for the site, defined as a circular area with a radius extending from the source to the most distant point where dispersion modelling predicts a significant ambient impact (greater than 5% of an AQS). The parameters that are emitted to atmosphere and that have been modelled in this study are nitrogen dioxide, TOC and particulate matter. The corresponding air quality standards are set out in Table 35, together with the corresponding significance levels based upon the EPA s 5% threshold level. 287-X0245 March 2015

40 Air Dispersion Modelling Study in Support of Application for Review of IE Licence 32 Table 35: Air Quality Standards and Significance Levels Parameter Averaging Period Air Quality Standard Significance Level Nitrogen dioxide 1-hour Annual 200 µg/m 3 10 µg/m 40 µg/m 3 2 µg/m 3 3 Total Organic Carbon 1-hour 0.1 mg/m mg/m 3 Particulate Matter (as PM 10 ) Note 1 Daily Annual 50 µg/m µg/m 40 µg/m µg/m 3 3 Particulate Matter (as PM 2.5 ) Note 1 Annual 25 µg/m µg/m 3 Note 1: There is no Air Quality Standard for Total Particulate Matter and therefore the assessment has been carried out on the basis of the PM 10 and PM 2.5 fractions. The distances to the corresponding significance levels for each of the parameters discharged to atmosphere over the various averaging periods were extracted from the air dispersion model. The longest distances arise in the case of nitrogen dioxide and correspond to the 1-hour, 99.8 th percentile ground level concentrations, yielding an impact area with a radius of c. 2 km, centred on the CHP plant Adjacent Licensed Facilities The closest active licensed sites to the site are listed in Table 36, with the closest of these sites almost 3.5 km. Table 36: Closest Active Licensed Sites to Diageo St. James s Gate Note 1 Reg. No. Site Distance from Site (km) P Jamestown Metal Resources Limited 3.5 P Colorman (Ireland) Limited 3.5 P Jamestown Shot Blasting & Metal Coating Limited 3.5 P Everlac Paints Limited 3.7 P Brooks Thomas Limited 3.7 P Ultra Packaging Ltd 3.9 W Dean Waste Co. Ltd. (Waste Transfer Station) 3.9 W Eco-Safe System Limited 3.9 P James McMahon Limited 4.0 P C V P Ltd 4.0 W Swalcliffe Limited (Waste Transfer Station) 4.0 Note 1: The EPA s online mapping system identifies additional licensed sites within 3 to 4 km of the St. James s Gate site; however, these sites have ceased activities and therefore are not required for this assessment. 287-X0245 March 2015

41 Air Dispersion Modelling Study in Support of Application for Review of IE Licence 33 As none of these sites lie within the impact area of the emissions from St James Gate, a cumulative impact assessment is not required. This is in accordance with the flowchart in Appendix F of the EPA s Air Dispersion Modelling Guidance Note. 6.6 Protection of Vegetation As noted in previous air dispersion modelling studies, Schedule 13 of the Air Quality Standards Regulations 2011 sets out the critical levels for sulphur dioxide and oxides of nitrogen in order to provide for the protection of vegetation. For oxides of nitrogen, the critical level is set at 30 μg/m 3 (as NO X ), on an annual average basis. Schedule 3 of the Regulations, which sets out the process for assessing ambient air quality and for locating sampling points, states the following in relation to the protection of vegetation and natural ecosystems: Sampling points targeted at the protection of vegetation and natural ecosystems shall be sited more than 20 km away from agglomerations or more than 5 km away from other builtup areas, industrial installations or motorways or major roads with traffic counts of more than 50,000 vehicles per day, which means that a sampling point must be sited in such a way that the air sampled is representative of air quality in a surrounding area of at least 1,000 km 2. In light of the guidance in this schedule, ambient monitoring of NO X for the protection of vegetation is not appropriate for large agglomerations, built up urban areas, or highly trafficked areas. In addition, the EPA s report Air Quality in Ireland 2013 Key Indicators of Ambient Air Quality, notes that the NO X annual mean limit value for the protection of vegetation only applies to rural stations in Zone D, while the EPA s Review of Ambient Air Quality Monitoring in Ireland (December 2010) also notes that assessment for compliance with limits and target values for protection of vegetation is not necessary at urban or suburban stations. The EPA s monitoring stations at Winetavern Street and Coleraine Street are located in the Zone A air quality zone (the Greater Dublin Area). Therefore, based upon the guidance set out in the Regulations on the location of monitoring stations, and the acknowledgement by the EPA that the annual mean limit value for the protection of vegetation does not apply to urban settings, the modelled results were not assessed against the critical NO X levels for the protection of vegetation. 7 SENSITIVITY STUDY This air dispersion modelling study is the third such study that has been carried out for Diageo St. James s Gate in recent years. In the first such study, a detailed sensitivity study was carried out in accordance with the EPA s guidance. The findings from the sensitivity study showed that, in most cases, where the inputs were changed for the sensitivity analysis (e.g. adjusting volume flow, neglecting building downwash, adjusting stack height), the resulting impacts to the surrounding area were reduced, and the model calculated reduced ground level concentrations for the various parameters emitted. The most significant difference was in the case of building downwash; much lower ground level concentrations (nearly an order of magnitude lower) were calculated in the sensitivity test where downwash was not considered. 287-X0245 March 2015

42 Air Dispersion Modelling Study in Support of Application for Review of IE Licence 34 The only exception to this pattern was in the case of terrain data. In this case, the model results showed that if terrain data was omitted then the maximum ground level concentrations would increase, albeit only slightly. Based on these findings, it was demonstrated that the outputs from the model (the predicted ground level concentrations) were conservative. Therefore, as the approach undertaken in the current study is the same as for the previous studies two studies, the outputs from this air dispersion modelling study are also considered to be conservative, robust and valid. 8 CONCLUSIONS 8.1 Overview The following are our conclusions from the air dispersion modelling study. For clarity, the conclusions for the various parameters have been identified separately, with an overall assessment of the impact from the site on the surrounding environment set out in Section The modelling has been conducted in accordance with the EPA s Air Dispersion Modelling from Industrial Installations Guidance Note (AG4). 2. The background concentrations of nitrogen dioxide and particulate matter (PM 10 and PM 2.5 ) from the EPA s monitoring stations take into account the contribution from the existing emissions to atmosphere from the site. 3. The modelling has been conducted on a conservative basis, with the emission points assumed to operate on a 24 hour per day, 7 day per week basis, and all assumed to operate at their respective licence limits (or proposed licence limits for the new emission points). 8.2 Nitrogen Oxides 4. The annual average background concentration of nitrogen dioxide in the vicinity of the site and within Dublin City Centre is in the order of 25 μg/m 3 to 34 μg/m 3, representing between 65% and 88% of the air quality standard of 40 mg/m The predicted 99.8 th percentile, 1-hour ground level concentration of nitrogen dioxide under both the current configuration (three roasters and afterburners) and the proposed configuration (four roasters and afterburners) is less than the air quality standard of 200 μg/m The predicted annual average ground level concentration of nitrogen dioxide for the current and proposed configurations is also lower than the air quality standard of 40 μg/m The maximum allowable process contribution of nitrogen dioxide, expressed as an annual average and based upon an average of the last three years of background data, is 7.5 μg/m 3. The predicted annual average process contribution of nitrogen dioxide resulting from the new development, if all four roasters were to operate simultaneously, is 2.81 μg/m The maximum calculated 98 th percentile NO 2 concentration, taking account of both the process contribution and the background levels, is μg/m 3. This is less than 75% of the 1-hour ambient air quality standard of 200 mg/m The installation and operation of the fourth roaster will not result in contravention of the air quality standards for oxides of nitrogen and the process contributions meet the criteria set out in the EPA s guidance. 287-X0245 March 2015

43 Air Dispersion Modelling Study in Support of Application for Review of IE Licence Total Organics 10. The highest 99 th percentile, one hour ground-level concentration of Total Organics is calculated to be significantly less than the derived air quality guideline of 0.1 mg/m The maximum predicted Process Contribution is calculated to be mg/m 3, which is significantly less than the Maximum Allowable Process Contribution (0.067 mg/m 3 ) as calculated in accordance with the EPA s guidance. 12. The predicted ground level concentrations of the individual organic constituents are less than the derived air quality standards, as set out in the EPA s guidance. 8.4 Particulate Matter 13. There is no data available on background concentrations of Total Particulate Matter. The background data that are available in the vicinity of the site are expressed in terms of PM 10 and PM 2.5. A small fraction of the Total Particulate Matter emitted to atmosphere from the site comprises PM 10, and a smaller fraction again comprises PM In the previous air dispersion modelling study, in which higher mass emission rates for the pale and roast dust extraction systems (A2-15 and A2-16) were modelled, the highest off site ground level concentrations of PM 10 and PM 2.5 occurred in the vicinity of the RMH building on the Lower Level, with the highest off site ground level concentrations of Total Particulate Matter occurring in the vicinity of the grain intake area on the Upper Level. The reduction in the mass emission rate from these two points has resulted in a reduction in the ground level concentrations of particulate matter in the vicinity of the RMH building. In addition, the highest offsite ground level concentration of Total Particulate Matter, PM 10 and PM 2.5 has also reduced. 15. The incremental contribution from the rice dust emission point, which was not previously modelled, is not significant and is less than the air quality standard for both PM 10 and PM The predicted 90.4 th percentile ground level concentration of PM 10 for the future configuration of the site (the changes to A2-15 & A2-16, the introduction of the rice dust emission point, and the addition of the cooling stack on the fourth roaster) is less than the air quality standard of 50 μg/m The predicted annual average ground level concentration of PM 10 for the future configuration of the site (the changes to A2-15 & A2-16, the introduction of the rice dust emission point, and the addition of the cooling stack on the fourth roaster) is significantly less than the air quality standard of 40 μg/m The predicted annual average ground level concentration of PM 2.5 for the future configuration of the site (the changes to A2-15 & A2-16, the introduction of the rice dust emission point, and the addition of the cooling stack on the fourth roaster) is significantly less than the air quality standard of 25 μg/m The maximum allowable process contribution of PM 10, expressed as an annual average and based upon an average of the last three years of background data, is 17.7 μg/m 3. The maximum predicted process contribution for the future configuration of the site (the changes to A2-15 & A2-16, the introduction of the rice dust emission point, and the addition of the cooling stack on the fourth roaster) is 2.01 μg/m X0245 March 2015

44 Air Dispersion Modelling Study in Support of Application for Review of IE Licence The maximum allowable process contribution of PM2.5, expressed as an annual average and based upon an average of the last three years of background data, is 10.2 μg/m 3. The maximum predicted process contribution is μg/m Overall Site Impact 21. The offsite ground level concentrations of nitrogen dioxide are shown to be less than the air quality standard. 22. The offsite ground level concentrations of Total Organics are shown to be below the air quality guideline value. In addition, the concentrations of the constituent organic compounds are also shown to be less than the corresponding derived environmental assessment levels. 23. The offsite ground level concentrations of particulate matter (TPM, PM 10 and PM 2.5 ) are shown to be less than their respective air quality standards. * * * * * 287-X0245 March 2015

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46 Air Dispersion Modelling Study in Support of Application for Review of IE Licence APPENDIX A SITE LAYOUT 287-X0245 March 2015

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50 Air Dispersion Modelling Study in Support of Application for Review of IE Licence APPENDIX B WIND ROSES FOR DUBLIN AIRPORT (2008, 2009 & 2010) Figure 7: Wind Rose for Dublin Airport (2008) Figure 8: Wind Rose for Dublin Airport (2009) 287-X0245 March 2015

51 Air Dispersion Modelling Study in Support of Application for Review of IE Licence Figure 9: Wind Rose for Dublin Airport (2010) 287-X0245 March 2015

52 Air Dispersion Modelling Study in Support of Application for Review of IE Licence APPENDIX C BACKGROUND MONITORING DATA 287-X0245 March 2015

53 Byrne Ó Cléirigh Ltd., 30A Westland Square, Pearse Street, Dublin 2, Tel: admin@boc.ie Client: Project: Title: Diageo Ireland Air Dispersion Modelling in Support of Review of IE Licence P Background Concentration of Ozone: Rathmines, Drg. No.: Figure C.1 FBS: 416: Date: March 2015

54 Byrne Ó Cléirigh Ltd., 30A Westland Square, Pearse Street, Dublin 2, Tel: admin@boc.ie Client: Project: Title: Diageo Ireland Air Dispersion Modelling in Support of Review of IE Licence P Background Concentration of Ozone: Clonskeagh, Drg. No.: Figure C.2 FBS: 416: Date: March 2015

55 Byrne Ó Cléirigh Ltd., 30A Westland Square, Pearse Street, Dublin 2, Tel: admin@boc.ie Client: Project: Title: Diageo Ireland Air Dispersion Modelling in Support of Review of IE Licence P Background Concentration of NO 2 : Coleraine Street, Drg. No.: Figure C.3 FBS: 416: Date: March 2015

56 Byrne Ó Cléirigh Ltd., 30A Westland Square, Pearse Street, Dublin 2, Tel: admin@boc.ie Client: Project: Title: Diageo Ireland Air Dispersion Modelling in Support of Review of IE Licence P Background Concentration of NO 2 : Drg. No.: Figure C.4 FBS: 416: Date: March 2015

57 Byrne Ó Cléirigh Ltd., 30A Westland Square, Pearse Street, Dublin 2, Tel: admin@boc.ie Client: Project: Title: Diageo Ireland Air Dispersion Modelling in Support of Review of IE Licence P Background Concentration of PM 10 : Winetavern Street, Drg. No.: Figure C.5 FBS: 416: Date: March 2015

58 Byrne Ó Cléirigh Ltd., 30A Westland Square, Pearse Street, Dublin 2, Tel: admin@boc.ie Client: Project: Title: Diageo Ireland Air Dispersion Modelling in Support of Review of IE Licence P Background Concentration of PM 2.5 : Coleraine Street, Drg. No.: Figure C.6 FBS: 416: Date: March 2015

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60 Air Dispersion Modelling Study in Support of Application for Review of IE Licence APPENDIX D CONTOUR PLOTS FROM DISPERSION MODEL 287-X0245 March 2015

61 Ordnance Survey Ireland Licence No. AR Ordnance Survey Ireland/Government of Ireland Byrne Ó Cléirigh Ltd., 30A Westland Square, Pearse Street, Dublin 2, Tel: admin@boc.ie Client: Project: Title: Diageo Ireland Air Dispersion Modelling in Support of Review of IE Licence P Contour Plot for NO 2 : 99.8 th Percentile, 2010 Weather Data Drg. No.: Figure D.1 FBS: 416: Date: March 2015

62 Ordnance Survey Ireland Licence No. AR Ordnance Survey Ireland/Government of Ireland Byrne Ó Cléirigh Ltd., 30A Westland Square, Pearse Street, Dublin 2, Tel: admin@boc.ie Client: Project: Title: Diageo Ireland Air Dispersion Modelling in Support of Review of IE Licence P Contour Plot for NO 2 : Annual Average, 2010 Weather Data Drg. No.: Figure D.2 FBS: 416: Date: March 2015

63 Ordnance Survey Ireland Licence No. AR Ordnance Survey Ireland/Government of Ireland Byrne Ó Cléirigh Ltd., 30A Westland Square, Pearse Street, Dublin 2, Tel: admin@boc.ie Client: Project: Title: Diageo Ireland Air Dispersion Modelling in Support of Review of IE Licence P Contour Plot for TOC: 99 th Percentile, 2010 Weather Data Drg. No.: Figure D.3 FBS: 416: Date: March 2015

64 Ordnance Survey Ireland Licence No. AR Ordnance Survey Ireland/Government of Ireland Byrne Ó Cléirigh Ltd., 30A Westland Square, Pearse Street, Dublin 2, Tel: admin@boc.ie Client: Project: Title: Diageo Ireland Air Dispersion Modelling in Support of Review of IE Licence P Contour Plot for Total Particulate: 90.4 th Percentile, 2010 Weather Data Drg. No.: Figure D.4 FBS: 416: Date: March 2015

65 Ordnance Survey Ireland Licence No. AR Ordnance Survey Ireland/Government of Ireland Byrne Ó Cléirigh Ltd., 30A Westland Square, Pearse Street, Dublin 2, Tel: admin@boc.ie Client: Project: Title: Diageo Ireland Air Dispersion Modelling in Support of Review of IE Licence P Contour Plot for Total Particulate: Annual Average, 2009 Weather Data Drg. No.: Figure D.5 FBS: 416: Date: March 2015

66 Ordnance Survey Ireland Licence No. AR Ordnance Survey Ireland/Government of Ireland Byrne Ó Cléirigh Ltd., 30A Westland Square, Pearse Street, Dublin 2, Tel: admin@boc.ie Client: Project: Title: Diageo Ireland Air Dispersion Modelling in Support of Review of IE Licence P Contour Plot for PM 10 : 90.4 th Percentile, 2009 Weather Data Drg. No.: Figure D.6 FBS: 416: Date: March 2015

67 Ordnance Survey Ireland Licence No. AR Ordnance Survey Ireland/Government of Ireland Byrne Ó Cléirigh Ltd., 30A Westland Square, Pearse Street, Dublin 2, Tel: admin@boc.ie Client: Project: Title: Diageo Ireland Air Dispersion Modelling in Support of Review of IE Licence P Contour Plot for PM 10 : Annual Average, 2008 Weather Data Drg. No.: Figure D.7 FBS: 416: Date: March 2015

68 Ordnance Survey Ireland Licence No. AR Ordnance Survey Ireland/Government of Ireland Byrne Ó Cléirigh Ltd., 30A Westland Square, Pearse Street, Dublin 2, Tel: admin@boc.ie Client: Project: Title: Diageo Ireland Air Dispersion Modelling in Support of Review of IE Licence P Contour Plot for PM 2.5 : Annual Average, 2009 Weather Data Drg. No.: Figure D.8 FBS: 416: Date: March 2015

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70 % of Air Quality Standard (AQS) % of Air Quality Standard (AQS) Byrne Ó Cléirigh Consulting Air Dispersion Modelling Study in Support of Application for Review of IE Licence APPENDIX E ASSESSMENT OF GROUND LEVEL CONCENTRATIONS AGAINST AIR QUALITY STANDARDS 100% Predicted Environmental Contribution of NO 2 Emissions in the context of the Annual Average AQS & Background Concentration 80% 18.7% 5.5% 7.0% 60% 40% 20% AQS 72.0% 72.0% 72.0% 0% AQS Max. Allowable PEC Existing PEC Future PEC Background Concentration Process Contribution 100% Predicted Environmental Contribution of NO 2 Emissions in the context of the 99.8 th percentile 1-hour AQS & Background Concentration 80% 60% 40% AQS 29.0% 16.0% 20.9% 20% 56.5% 56.5% 56.5% 0% AQS Max. Allowable PEC Existing PEC Future PEC Background Concentration Process Contribution 287-X0245 March 2015

71 % of Air Quality Standard (AQS) % of Air Quality Standard (AQS) Byrne Ó Cléirigh Consulting Air Dispersion Modelling Study in Support of Application for Review of IE Licence 100% Predicted Environmental Contribution of TOC Emissions in the context of the 99th percentile 1-hour Air Quality Guideline 80% 60% 40% 20% 0% AQS 66.7% 21.6% 28.6% 0.0% 0.0% 0.0% AQS Max. Allowable PEC Existing PEC Future PEC Background Concentration Process Contribution 100% Predicted Environmental Contribution of PM 10 Emissions in the context of the Annual Average AQS & Background Concentration 80% 60% 40% 20% 0% AQS AQS 44.2% 4.9% 5.0% 4.9% 5.0% 33.8% 33.8% 33.8% 33.8% 33.8% Max. Allowable PEC Existing PEC Existing + Roaster 4 PEC Existing + Rice Discharge PEC Future PEC Background Concentration Process Contribution 287-X0245 March 2015

72 % of Air Quality Standard (AQS) % of Air Quality Standard (AQS) Byrne Ó Cléirigh Consulting Air Dispersion Modelling Study in Support of Application for Review of IE Licence 100% Predicted Environmental Contribution of PM 10 Emissions in the context of the 90.4 th percentile daily AQS & Background Concentration 80% 60% 40% AQS 35.1% 10.6% 11.0% 10.8% 11.0% 20% 47.4% 47.4% 47.4% 47.4% 47.4% 0% AQS Max. Allowable PEC Existing PEC Existing + Roaster 4 PEC Existing + Rice Discharge PEC Future PEC Background Concentration Process Contribution 100% Predicted Environmental Contribution of PM 2.5 Emissions in the context of the Annual Average AQS & Background Concentration 80% 60% 40% AQS 37.6% 0.2% 0.2% 0.2% 0.2% 20% 43.6% 43.6% 43.6% 43.6% 43.6% 0% AQS Max. Allowable PEC Existing PEC Existing + Roaster 4 PEC Existing + Rice Discharge PEC Future PEC Background Concentration Process Contribution 287-X0245 March 2015

73 Industrial Emissions, Application Form, V.3.0, January 2015 Attachment I.4 Ground and / or Groundwater Contamination This attachment contains the following: I4.1 Baseline Report 287-X0244 March 2015

74 Baseline Report in Support of an Application for a Review of Industrial Emissions Licence P Prepared for: Diageo Ireland Ref: 287-X0246 March 2015 Byrne Ó Cléirigh, 30a Westland Square, Pearse Street, Dublin 2, Ireland. Telephone: Facsimile: Admin@boc.ie. Web: Directors: LM Ó Cléirigh BE MIE CEng FIEI FIMechE; TV Cleary BE CEng FIEI FIChemE; LP Ó Cléirigh BE MEngSc MBA CEng MIEI; ST Malone BE MIE CEng MIEI; JB FitzPatrick FCA. Registered in Dublin, Ireland No